John Lothian Newsletter: ICE Asks SEC to Clear European Sovereign Swaps; S&P found guilty of misleading investors; BATS Chi-X Europe Introduces New Interbook Order Types

Nov 5, 2012

IntercontinentalExchange asks the SEC for permission to take on a new project: clearing swaps for five countries in Europe. Standard & Poor’s gets taken to the woodshed in Australia, as a judge rules that the company did indeed mislead investors by slapping an “A-OK” rating onto rickety products that collapsed in 2008. BATS Chi-X Europe adds two new types of interbook orders to its lineup for testing, and has plans to take the new orders live later this month.

First Read

Regulators cooling over rule changes
Farah Khalique – Financial News
Leading figures across the financial services industry have suggested that there is growing evidence of regulators softening their stance on the wholesale imposition of Europe-wide rule changes.

**** Winter comes to regulatory fervor?


Asian futures markets primed for take-off
Tom Osborn – Financial News
The liberalisation of China’s markets combined with a growing desire to do business in the east is driving growth in Asia. In the past year, the embodiment of this power shift was the almost £1.4bn sale of the London Metal Exchange to Hong Kong Exchanges and Clearing.

**** How is the legal and banking environment?


ICE Reports 2% Increase in October Futures Volume; Over $35 Trillion of CDS Cleared to date
IntercontinentalExchange (NYSE: ICE), a leading operator of global markets and clearing houses, today reported futures volume for October 2012. ICE’s average daily volume (ADV) for futures and options was 3,398,912 contracts, an increase of 2% from the prior October. Year-to-date through October 31, ADV rose 12% to 3,437,174 contracts, compared to the first ten months of 2011. Total contract volume in October 2012 increased 11% compared to the prior October, to 78.2 million contracts


CBOE Secures Victory Over ISE on Index Options
Jacob Bunge – Dow Jones
The Chicago Board Options Exchange on Friday said it secured a court victory over a smaller rival seeking to offer contracts resembling the CBOE’s most popular options.

**** Is this victory another battle or is the war over?


Fidessa’s Compliance Solution Named Best In Class At Buy-Side Technology Awards – Wins This Prestigious Award For Fifth Successive Year
Fidessa group plc, provider of high-performance trading, investment management and information solutions for the world’s financial community, has today announced that its buy-side compliance solution has scooped the top spot for the fifth consecutive year at the annual Buy-Side Technology Awards.


CME Group Volume Averaged 9.9 Million Contracts per Day in October 2012
CME Group, the world’s leading and most diverse derivatives marketplace, today announced that October 2012 volume averaged 9.9 million contracts per day, down 20 percent from October 2011. Total volume for October 2012 was more than 227 million contracts, of which 87 percent was traded electronically.

**** The sun will come out tomorrow,….


Haldane’s mystery absence from HFT probe
Tim Cave – Financial News
The name of Andrew Haldane, executive director for financial stability at the Bank of England and a leading critic of high-frequency trading, has disappeared as a signatory to a Treasury-sponsored report that gave broad support to the high-speed trading industry, stoking the controversy around the project.


Hedge fund masters flunk money-making test
Reuters via Yahoo! Finance
Generating strong returns is getting so tough for hedge fund managers, supposedly the high-earning masters of any market, that some are shutting up shop and more look poised to follow. Years of choppy markets whipsawed by political risk have crippled performance and left many firms with little in the way of income earned by hefty fees.

**** This is always the case.


Farnham to exit Turquoise for LME
Tim Cave – Financial News
The chief executive of the London Stock Exchange’s equities and derivatives platform Turquoise has resigned and is set to join the London Metal Exchange, Financial News has learned.


Brokers look to Orb for new revenue
Vanessa Kortekaas –
Stockbrokers have had little reason to cheer in the past year. Several industry players have been taken over by larger groups – making it harder for those remaining to win the confidence of new clients – and UK equity trading volumes have remained depressed.

**** Consolidation has happened for years. Check the names of the firms 5 or 10 years ago.


After scandals, Chicago says best derivatives model is theirs
Karen Brettell – Reuters
The big-bank dominated model for privately traded derivatives is broken and those in the futures business argue that the fix is in Chicago.

**** And our pizza is the best too.


Time for investment banks to bite the bullet and wield the axe
William Wright – Financial News
A “strategic acceleration from a position of strength” sounds a lot better than a “humiliating retreat after more than a decade of strategic failure”. But the carefully chosen wording of UBS’s announcement about the radical restructuring of its investment bank can’t hide the fact that the Swiss bank – and many of its rivals – has been in denial for years.

**** Another hatchet job?


Todd Fulton

Todd Fulton of Pioneer Futures on What Investors Want in Emerging Managers (Part 1 of 2)
Todd Fulton, Vice President, Managed Futures at Pioneer Futures, has been around the CTA space for more than 20 years. He spoke with JLN Managed Futures editor Jim Kharouf about just what it is that attracts investors to emerging CTAs, why he isn’t sold on Sharpe ratios, what fees really are and the future for managed futures.

Watch the video »

JLN Metals

Barrick Gold Profit Trails Estimates as Mining Costs Increase
Barrick Gold Corp. , the world’s biggest producer of the precious metal, reported third-quarter earnings and sales that missed analysts’ estimates after mining costs rose more than expected.

Johannesburg Stock Exchange Adds Silver And Platinum Commodities To Quanto Futures Product Range
The Johannesburg Stock Exchange (JSE) has again expanded its commodities product range by adding silver and platinum quanto futures to its existing gold, copper and Brent crude Quanto Futures which were launched earlier this year.

China sees mounting aluminum stockpiles
Aluminum stockpiles in the main trading regions in China have climbed to the highest level in two years as growth in supply outpaces demand in the world’s largest user, according to two industry surveys.


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Lead Stories

Intercontinental Asks SEC to Clear European Sovereign Swaps
Matthew Leising – Bloomberg
Intercontinental Exchange Inc., owner of the world’s largest credit-default swaps clearinghouse, requested permission from the Securities and Exchange Commission to back contracts for sovereign debt of five European countries.

S&P found guilty of misleading investors
Neil Hume in Sydney –
Standard & Poor’s misled investors by awarding its prized triple A rating to a complex structured finance product that collapsed in value during the financial crisis, an Australian judge has ruled, in a landmark case that paves the way for similar action in Europe and the UK.

S&P Loses Landmark Australian Derivatives Case
Dow Jones
Standard & Poor’s lost a landmark case in Australia Monday over top-flight ratings given to financial products that collapsed in the build-up to the 2008 global economic crisis.

BATS Chi-X Europe Introduces New Interbook Order Types
BATS Chi-X Europe, the largest pan-European equities market operator by market share and notional value traded, today introduced ‘Lit Sweep’ and ‘Dark Sweep’, its new interbook order types. Lit Sweep and Dark Sweep order types are currently available for testing by BATS Chi-X Europe participants. The order types are scheduled to go live on Monday, 12th November.

MCX-SX to launch when 350 members get connected
Reuters via Yahoo! Finance
MUMBAI – MCX-SX, India’s new stock exchange, will formally launch trading in equity, equity futures and options and other segments once it gets 350 trading members connected to its systems, according to a statement issued on Friday.

HSBC Prepares to Face U.S. Money Laundering Charges
Howard Mustoe and Gavin Finch – Bloomberg
HSBC Holdings Plc (HSBA) said it’s likely to face criminal charges from U.S. anti-money laundering probes and the cost of a settlement may “significantly” exceed the $1.5 billion the bank has set aside.

European banks resume their euro retreat
Farah Khalique – Financial News
Last month, Crédit Agricole announced it was selling its Greek banking arm Emporiki to Alpha Bank for E1 ($1.3), adding that it would take a E2bn hit to its bottom line as a result of the sale. Two days later, fellow French bank Societe Generale announced it had sold its majority stake in Greece’s Geniki bank to Piraeus bank.

A patented randomised investment bank restructuring announcement generator
William Wright – Financial News
When a big European bank takes the radical action of closing down large parts of its investment banking business, you know the game is up. And so it was a few weeks ago when ING shocked its rivals by announcing that it was cutting around 30 staff in its UK corporate finance team and some 100 employees in its central and eastern European and Russian equities business. The shock, of course, was that the Dutch bank was in these businesses at all.

Tokyo-Osaka exchange seeks to become Asian hub
Tim Cave – Financial News
The merger mania that gripped stock exchanges last year promised so much but, amid a rising wave of patriotic and protectionist sentiment, ultimately delivered little in deal success.

BSE confirms Chauhan as new CEO
Neil Munshi in Mumbai –
Ashishkumar Chauhan has been appointed managing director and chief executive of the Bombay Stock Exchange, Asia’s oldest bourse, according to a statement released on Friday.

One Safety Net That Needs to Shrink
Gretchen Morgenson –
Eight lucky financial institutions got the best of both worlds under Dodd-Frank: access to the Fed’s money and no penalty for failure.


Distribution review set to drive wealth M&A
Sophie Baker – Financial News
Wealth managers are bracing themselves for a wave of consolidation in the wake of the Retail Distribution Review that will bring sweeping changes to the industry when it becomes law in two months.

G20 may punish bank capital reform delinquents: officials
Reuters via Yahoo! News
MEXICO CITY – The world’s biggest economies will soon discuss how to punish countries that fail to implement tougher new bank rules in a crucial test of their resolve to prevent another financial crisis, officials said.

Bernardino draws fire over Eiopa’s need for speed
Mark Cobley – Financial News
Gabriel Bernardino, chairman of Europe’s pensions and insurance regulator, did not have much time to watch the Olympics this summer. But he did catch Usain Bolt’s blistering performances on the track: “Fabulous!” Pension fund organisations across Europe have been slightly less impressed by the speed with which Bernardino’s organisation, the European Insurance and Occupational Pensions Authority, has required them to move in recent months.

European firms await AIFMD onslaught
Kiel Porter – Financial News
The European Union’s Alternative Investment Fund Managers Directive – which aims to regulate private equity and hedge funds – is just nine months away, but a new survey has shown that most firms are unprepared, and industry executives say some are ready to move offshore until they see how the new rules will work.

The Challenges Facing ASIC Over The Next Decade
A speech by ASIC Chairman, Greg Medcraft, delivered at the American Chamber of Commerce in Australia Business Leaders’ Lunch, Hilton Sydney, 2 November 2012

Financial Stability Board: Update On Global Adherence To Regulatory And Supervisory Standards On International Cooperation And Information Exchange

Exchanges & Trading Facilities

IntercontinentalExchange Reports Third Quarter Earnings; Diluted EPS of $1.79
IntercontinentalExchange, Inc. (NYSE: ICE), a leading operator of global markets and clearing houses, today reported financial results for the third quarter of 2012. Consolidated revenues were $323 million, a decrease of 5% compared to the third quarter of 2011. Consolidated net income attributable to ICE was $131 million, down 1% versus the third quarter of 2011. Diluted earnings per share (EPS) were $1.79, down 1% from the prior third quarter.

BOX Price Improvement Activity for October
Boston, November 1, 2012: In the month of October, price improved contracts on BOX Options Exchange (“BOX”) averaged 229,858 per day. Overall average daily trading volume on BOX in the month of September was 513,737 contracts.

TMX Group Consolidated Trading Statistics – October 2012 Toronto Stock Exchange – TSX Venture Exchange, TMX Select, Alpha, Montreal Exchange, NGX
TSX Venture Exchange experienced an 11% increase in volume in October 2012 from September 2012 and was up 3% compared to the same month a year earlier. Volume on Toronto Stock Exchange was down 8% compared to September 2012 and was down 26% compared to October 2011.

ASX Group Monthly Activity Report – October 2012
In October 2012 the average daily number of trades was 14% lower than the pcp, and the average daily value of trading was 24% lower than the pcp. ASX, after consultation with ASIC, will not be proceeding with its plans to quote Unsponsored Depository Receipts on international stocks at this time.

ASX Compliance Monthly Activity Report – October 2012

SGX Derivatives and Clearing Volumes Grow
Singapore Exchange (SGX) recorded volume growth in derivatives and commodities trading and clearing in October but securities market activity declined. Securities: Turnover fell 6% year-on-year to S$26.0 billion while daily average value (SDAV) was 14% lower at S$1.2 billion. Compared with September, turnover fell 8% while SDAV was 16% lower. Financial Derivatives: Volume grew 20% year-on-year to 7.0 million contracts and daily average volume was 10% up at 333,464 contracts.

The Spanish Exchange turnover in Equities reached E70.38bn in October, up 44% on September and down 10% on the same month a year earlier. The trading volume in the Spanish Stock Exchange was E599.48bn to the end of October, down 24.8% on the same period last year.

TOM MTF Statistics Week 44

NZX Monthly Metrics – October 2012

CBOE Wins: ISE Prohibited From Trading “ISE Max Spy Index” Options
Press Release

NZX Board Announcement

NZX: Resignation – Rowan Macrae

NZX Dividend Announcement

Restoration Hardware Holdings, Inc. Celebrates Initial Public Offering and First Day of Trading on the New York Stock Exchange

[CBOE] Trader E-News

[CBOE] Auction Message Responses and Redistribution

[CBOE] November 2012 Fee Changes

Hedge Funds & Managed Futures

Wells Fargo eyes fund of hedge fund businesses
Mike Foster and William Hutchings – Financial News
Wells Fargo Asset Management is in the market for a fund of hedge funds business with assets under management of up to $12bn.

Cern applies science to pension fund
Sophie Baker – Financial News
Managers of the Sfr3.8bn ($4bn) pension scheme for those behind the discovery of the Higgs boson, or “God particle”, are searching for the “holy grail” of a different kind. The European Organization for Nuclear Research has chosen technology firm TradingScreen to provide foreign exchange trading and transaction cost analysis services.

Hedge Funds Reduce Bullish Bets Most in Five Months: Commodities
Hedge funds cut bullish wagers on commodities by the most since June as prices retreated to a three-month low on mounting concern that Europe’s debt crisis will worsen and U.S. growth slow.

Och-Ziff Capital Management Group LLC Reports 2012 Third Quarter Results
Och-Ziff Capital Management Group LLC today reported a GAAP Net Loss(1) of $127.5 million, or $0.89 per basic and diluted Class A Share, for the third quarter ended September 30, 2012.

Brevan Howard Said to Hire Goldman Sachs Credit Trader Leslie
Brevan Howard Asset Management LLP, Europe’s second-largest hedge fund, hired Goldman Sachs Group Inc. credit trader Wayne Leslie, said a person with knowledge of the matter.

Pimco Says Embattled 1-Year Mortgage Bonds Denmark’s Top Buy
Short-term Danish mortgage bonds, singled out by the central bank and rating companies as a threat to the $500 billion industry, are the best debt investment in Denmark, according to the head of Pacific Investment Management Co. ’s covered bond operations in Europe.

Berkshire Profit Climbs 72% on Derivatives, Railroad
Warren Buffett ’s Berkshire Hathaway Inc. said profit climbed 72 percent in the third quarter on better results from its derivatives book and higher earnings at railroad Burlington Northern Santa Fe.

Cargill CFO to step down at month’s end; President and COO to become interim CFO
Cargill today announced that Sergio Rial, its chief financial officer, will resign his post with the company effective at the end of November in order to return to his native Brazil for personal reasons. Cargill President and Chief Operating Officer David MacLennan will serve as interim chief financial officer until the Cargill Board of Directors elects a successor.

Swiss Property Market Edges into Risk Zone in 3Q -UBS Index
Dow Jones
Demand in Switzerland’s buoyant property market quickened in the third quarter as record low mortgage rates, the ongoing influx of wealthy migrants and a dearth of alternative investments intensified imbalances in the market, according to a market monitoring index released Monday.

Rothschild Said to Hire Morgan Stanley for Rival Bumi Proposal
Nathaniel Rothschild , who quit the board of Bumi Plc last month, has appointed Morgan Stanley to advise him on a plan to counter a $1.2 billion proposal for Bumi’s assets, a person familiar with the matter said.

Arabica-Coffee Futures Could Drop Further
Arabica-coffee prices are at nearly their lowest point since June, and market conditions point to still lower prices ahead.

CFTC.Gov Commitments Of Traders Reports Update

Boerse Stuttgart: End Of Subscription Period For Mox Telecom AG Bond – Trading On Bondm Started On 1 November 2012

Banks & Brokers

Citadel’s Griffin Sparked E*Trade Stock-Order Review
E*Trade Financial Corp. agreed to improve order-handling practices after Kenneth Griffin, a director who also runs a competing trading firm, raised concerns over whether the brokerage delivered on its promise to execute trades as quickly and as cheaply as it could for its 2.9 million brokerage customers.

Analysis: Barclays set to fight FERC over bragging, not rigging
Reuters via Yahoo! News
NEW YORK – British bank Barclays is set to fight a potentially record $470 million penalty from U.S. energy regulators by arguing its traders were guilty of braggadocio, not of rigging California electricity prices.

UBS Names Investment Banking Leadership Group
Dow Jones
UBS AG appointed a handful of bankers to run its retooled investment-banking operation, days after the Swiss bank announced a sweeping overhaul that will sharply decrease the risk and size of the division.

RBS to Settle Libor, Nomura Insider Trading: Compliance
Royal Bank of Scotland Group Plc, Britain’s biggest taxpayer-owned lender, said it expects to pay a fine in the coming months to settle regulators’ probes into allegations the lender tried to manipulate Libor.

New Accounting Rules to Force UK Banks to Raise Cash – Report
Dow Jones
U.K. banks will be forced to raise tens of billions of pounds in fresh capital as a result of new accounting rules due to be announced early next year, according to the Sunday Telegraph newspaper, which didn’t say where it got its information.

Former Icap equities chief joins Sunrise
Tom Osborn – Financial News
Sunrise Brokers has hired Daryl Bowden as managing director of equities, as the London-based firm continues its aggressive expansion into cash broking and specialist equity research.

Goldman Sachs trims partner list to help cut expenses
Reuters via Yahoo! News
Goldman Sachs Group Inc has cut the number of employees it lists as partners to help streamline expenses. Goldman has reduced the number of partners to 407, down 31 from February, the bank said in a filing with the U.S. Securities and Exchange Commission, without identifying the partners that had been dropped.

Prudential to Buy Thai Thanachart Life Assurance for $585 Million
Dow Jones
U.K.-based Prudential PLC has agreed to acquire the life-assurance unit of Thailand’s Thanachart Bank for $585 million, underscoring the keen interest among global insurers and investors in the fast-growing Southeast Asian market.

HSBC legal costs rise by $1.1 bln, shares slump
Associated Press via Yahoo! News
HSBC, Europe’s biggest bank, has set aside an additional $1.15 billion to cover potential U.S. fines for money laundering by its Mexican unit and penalties for mis-selling payment protection insurance.

DealBook: R.B.S. Expects Fine Over Libor Investigation
New York Times
The Royal Bank of Scotland said on Friday that it would probably face financial penalties connected to the rate-rigging investigation, as the British bank reported a net loss in the third quarter of the year.

SIFMA’s Municipal Securities Division Announces New Officers, 2013 Priorities – Morgan Stanley’s Shields Becomes Division Chair, Replaces Jefferies’ Kenneth Gibbs
SIFMA today announced that its Municipal Securities Division has elected new officers and members of its Municipal Executive Steering Committee and outlined its priorities for 2013.

Thomson Reuters Net Up but Revenue Falls
Thomson Reuters Corp. reported a 41% drop in operating income in the third quarter, signaling that difficulties persist in its core business serving financial professionals.

BGC Partners Reports Third Quarter 2012 Financial Results

Goldman Sachs Announces $10 Million in Hurricane Sandy Relief Funds

Clearing & Settlement

OTC clearers carve out niches in Asia
Michelle Price – Financial News
Policymakers in the Asia-Pacific region are preparing to implement the post-crisis reform agenda agreed by the G20 countries to transform the over-the-counter derivatives market.

DTCC Resumes Processing Of Physical Securities
The Depository Trust & Clearing Corporation announced today that it has resumed daily physical processing of securities from its Brooklyn operations center, re-establishing critical processing and mechanisms for clients to receive position credit for deposits, reorg entitlements, and Direct Registration System (DRS) statement withdrawals.

Indexes & Products

Demand for bespoke indices increases
Charlotte Moore – Financial News
Alternative indices are experiencing rapid growth, fuelled by high equity market volatility and the realisation that traditional market capitalisation-based indices have exposed investors to concentrated risk.

Wealthy shifting towards ETFs versus hedge funds, Berkshire
St. Louis Post-Dispatch
An elite group of U.S. millionaires would rather match the stock market through an exchange-traded index fund than try to beat it using higher-fee hedge funds or billionaire Warren Buffett’s holding company Berkshire Hathaway.



SEC wants Idaho nuke developer’s assets frozen
KTVB Boise
Securities and Exchange Commission lawyers want a federal judge to again freeze assets of a would-be Idaho nuclear power developer, saying its founder hid use of the company’s dwindling cash for a sham investment scheme. Alternate Energy Holdings Inc. also confirmed Friday that it’s being investigated by the U.S. Department of Justice.

SEC Asked Groupon for Financial Disclosures
The Securities and Exchange Commission this summer began pressing Groupon Inc. to disclose more details on revenue from its new business lines and on reasons behind the daily-deal site’s financial revision this spring, according to newly disclosed correspondence between the regulator and the company.

BCSC panel fines and permanently cease trades Bahamian company for misconduct and refusal to provide information

Environmental & Energy

Unprecedented world carbon emissions cuts needed by 2050: PwC
The world will have to cut the rate of carbon emissions by an unprecedented rate to 2050 to stop global temperatures from rising more than 2 degrees this century, a report released by PwC on Monday showed.

**RKB — Key numbers captured in this quote: “”Even doubling our current rate of decarbonisation would still lead to emissions consistent with 6C warming by the end of the century,” said Leo Johnson, PwC partner for sustainability and climate change. “To give ourselves a more than 50 percent chance of avoiding 2C will require a six-fold improvement in our rate of decarbonisation.”

New Zealand carbon scheme on hold as prices plunge
Just two years after expanding a scheme that was feted as the world’s only emissions trading scheme outside of Europe, New Zealand has effectively put the scheme on hold, just as other nations step into the carbon trading arena.

COLUMN – Why you need a climate change portfolio
Whether you believe in man-made global warming or not, it’s undeniable that trillions of dollars will be spent on technologies to address the collateral damage of climate change.

**RKB — Column highlights diversity within ETFs which importantly range from cleantech to water. It does not get into expenses and other detailed fund comparisons.


SGX Wins Industry’s Vote As Exchange Of The Year
Singapore Exchange (SGX) was recognised as the “Exchange of the Year 2012” at the Asia Risk Awards ceremony held in Hong Kong on 1 November 2012.

Foreign banks hope China’s new leaders will loosen up regulators
Reuters via Yahoo! News
SHANGHAI – For all the hopes that China’s forthcoming leadership change will herald a new wave of market reforms, foreign bankers don’t expect to get the level playing field they crave any time soon. Trends are positive, but progress can be frustratingly slow.

Video – Chinese Investors Get Red-Carpet Treatment in U.S.
Sun Wenbin and his colleagues from China got the red-carpet treatment on a recent trip to the U.S. Over 10 days, Mr. Sun and 60 other Chinese entrepreneurs and executives were welcomed by former President George W. Bush, and courted by businesses ranging from a shrimp breeder in Orlando to a real-estate developer in Dallas and an alternative-fuel company in Madison.

Matters of Concern in Relation to Changes in Trading Methods of Calendar Spreads
As previously announced(*), OSE will change the trading methods in futures calendar spreads starting from the Day Session on Monday, November 26, 2012. We ask that concerned personnel be notified about these matters as listed below.

Hong Kong’s Securities And Futures Commission: Appointment To Investor Education Advisory Committee

Press Conference By Ikko Nakatsuka, Japan’s Minister For Financial Services

Hong Kong’s Securities and Futures Commission Publishes Annual Review Of SEHK’s Performance In Regulating Listing Matters

Frontier Markets

Dubai Financial Market Quarterly Loss Narrows as Revenue Rises
Dubai Financial Market PJSC , the only publicly traded Gulf Arab stock market, said its third-quarter loss narrowed after revenue advanced and costs dropped.

Dubai Financial Market Company Net Profit Soars 411% To AED 38.9 Million During The First Three Quarters Of 2012

Results Of Dubai Financial Market PJSC Board Of Directors’ Meeting
The Board of Directors’ of Dubai Financial Market PJSC held a meeting on Saturday 3/11/2012 at 10:00 AM at Borse Dubai and approved the review report and condensed consolidated interim financial information for the nine month period ended 30 September 2012.

Saudi Stock Exchange (Tadawul) Monthly Statistical Report – October 2012

Malawi Stock Exchange Weekly Trading Report – 2nd November, 2012


Bonuses on Wall St. Expected to Edge Up
Wall Street employees, whose paychecks have often been cut in recent years, are likely to get a slight bump in their bonuses this year. The catch: the increase will come on top of one of the worst years for bank pay in recent memory.


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